These prohibitions are applicable wherever the
Group operates, regardless of the provisions of
local legislation.
Notwithstanding the above, gifts and hospitality
are considered acceptable when they meet the
following requirements:
They are not in breach of the legislation appli-
cable in each country.
They are not contrary to the Group’s ethical and
transparency-related values.
They are given or received as part of what is a
generally accepted act of social courtesy or
business practice and consist of objects or
services generally considered to be of symbolic
or economically irrelevant value.
If any act of corruption or bribery comes to your
attention, report it.
Competitors
The Lantero Group competes fairly and complies
with all the competition laws applicable around the
world. Employees who gather, share and use
information on our competitors must only do so
legally and ethically.
Always compete with integrity and comply with
applicable antitrust and competition laws.
When dealing with our competitors, you must
never enter into formal or informal, written or verbal
agreements to set prices or conditions of sale,
coordinate bids or assign customers, sales territo-
ries or product lines, or take part in any other
activity in breach of applicable antitrust and
competition laws.
Breaches of antitrust and competition laws may
lead to serious legal sanctions for the company
and criminal charges being filed against the
individuals involved.
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Conflicts of Interest
You must always avoid anything which may lead to
conflict between your personal interests (or those of
any member of your family) and the interests of the
company when carrying out an activity.
Conflicts of interest may arise when either you or a
member of your family receives any form of
personal or economic benefit from (or has a
financial interest in) or works for a supplier, custo-
mer, competitor or company seeking to do business
with the Group.
If at any point in your work, you think you may
have a real or potential conflict of interest, you must
inform the company immediately.
something of value (such as achieving a performan-
ce target or receiving payment) or avoid negative
consequences (such as disciplinary measures).
Confidential information
You must protect and not disclose confidential
competition-sensitive or proprietary information
about the Lantero Group, its customers, suppliers or
commercial partners, or third parties.
Disciplinary measures
If you fail to comply with its Unified Code, the
company may take the applicable disciplinary
measures according to the misconduct and sanc-
tion system in force at the time. The senior manage-
ment of the Lantero Group will ensure that this
Unified Code is complied with and its own
conduct should set an example for all the Group’s
employees.
the civil and criminal laws in force in the different
countries in which the Group operates.
You must assume that all company information is
confidential or competition sensitive unless there
are clear indications that the Lantero Group has
made it public.
Remember that having a conflict of interest is not
necessarily a breach of the Unified Code, but
failing to report one is.
Company resources
You must protect the Lantero Group’s resources.
The Group expects you to use the company’s
resources honestly and effectively.
The company’s resources include physical assets,
such as its facilities, supplies, equipment, machi-
nery, spare parts, raw materials, finished products,
vehicles and funds. They also include intangible
assets, such as confidential information, intellectual
property and information systems.
You must use the company’s resources only for
legitimate commercial purposes and protect them
against theft, loss, damage and improper use.
Your obligation to protect the company’s funds is
particularly important if you are authorized to
spend money, approve expenses or manage
budgets.
Fraud
Fraud consists of using the company’s resources in
an improper manner when you intentionally
conceal, alter, falsify or omit information for your
own personal benefit or for that of others. Fraud
may be motivated by the opportunity to obtain
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